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HOME GROUP, INC. v. C.I.R.

No. 901, Docket 88-4155.

875 F.2d 377 (1989)

The HOME GROUP, INC., as Agent Under the Provisions of Treasury Regulation Section 1.1502-77(d) for City Investing Company and the Consolidated Group of Which City Investing Company was the Common Parent, Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, Second Circuit.

Decided May 11, 1989.

Attorney(s) appearing for the Case

William L. Goldman, Washington, D.C. (George W. Beatty, Jane E. Wilson, and Lee, Toomey & Kent; Lester J. Mantell and Alan R. Sankin, New York City, on the brief) for appellant The Home Group, Inc.

Jonathan S. Cohen, Atty., Tax Div., Dept. of Justice, Washington, D.C. (James I.K. Knapp, Acting Asst. Atty. Gen., Gary R. Allen and Mary Frances Clark, Attys., on the brief) for appellee Commissioner of Internal Revenue.

Before OAKES, Chief Judge, TIMBERS and KEARSE, Circuit Judges.

TIMBERS, Circuit Judge:

Appellant The Home Group, Inc.1 appeals from a decision entered August 24, 1988 in the United States Tax Court, Joel Gerber, Judge,2 which determined deficiencies totalling $20,974,856 for the tax years 1968, 1969 and 1970 in the federal income taxes of the corporate taxpayer.

Home is a property and casualty insurer which issues...

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